Court: United States Court of Appeals for the Fifth Circuit

Filed: 2026-06-30

The Fifth Circuit affirmed the district court’s denial of Apple’s motion to quash the § 1782 subpoena but reversed the order denying Apple’s request for a supplemental protective order limiting disclosure of the A-B Agreements to outside counsel only. The court held that the district court erred in concluding that “applicable law” under German and Indian statutes superseded the contractual confidentiality provisions of the A-B Agreements, which restrict disclosure to outside counsel during litigation absent a specific governmental mandate. The court applied a de novo standard of review to the interpretation of the disputed contractual terms within the A-B Agreements. It determined that the magistrate judge’s reliance on foreign law was premature because neither the Indian nor German courts had issued an order or definitive mandate requiring the production of these agreements to in-house counsel at the time of the ruling. The court found that Malikie’s expert testimony established only that such disclosure “might” be required under foreign procedural rules, not that it was legally compelled. Consequently, the district court could not invoke the “applicable law” exception to override the “course of litigation” provision in the contract which mandated protection limited to outside counsel. The practical consequence is that the A-B Agreements must remain protected from disclosure to Xiaomi’s in-house counsel under the existing protective order terms. The case is remanded with instructions to enforce the contractual confidentiality provisions limiting access to outside counsel only, while leaving open the possibility for Malikie to seek a modification of the protective order in the future if a foreign court subsequently issues an order mandating broader disclosure.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-06-30

The Ninth Circuit denied Walid Majdub’s petition for review of the Board of Immigration Appeals’ (BIA) refusal to grant his second motion to reopen removal proceedings. The court held that the BIA did not abuse its discretion in denying the motion because it was both untimely and number-barred under 8 U.S.C. § 1229a(c)(7), having been filed more than four years after the final administrative order and constituting a second motion when generally only one is permitted. The court applied the standard that a motion to reopen based on changed country conditions may only be excused from these limits if the petitioner demonstrates: (1) evidence of changed conditions in the country of nationality; (2) materiality of that evidence; (3) that the evidence was unavailable at prior hearings; and (4) that the new evidence, combined with the old, establishes prima facie eligibility for relief. The court found the BIA acted within its discretion in concluding Majdub failed to meet these requirements regarding violence by Islamic extremist groups and violence against Palestinians by Jewish groups in Israel, noting that the Department of State’s 2012 report already documented similar conditions and that Majdub had previously raised similar claims. Furthermore, the court affirmed that the new evidence did not establish prima facie eligibility for asylum, withholding of removal, or protection under the Convention Against Torture, as Majdub failed to challenge prior findings regarding the Israeli government’s inability to control extremists or the lack of a likelihood of torture. The practical consequence is that the petition for review is denied, and Majdub’s motions for a stay of removal are also denied, though a temporary stay remains in effect until the mandate issues.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-06-30

The Ninth Circuit denied Marc Mendoza’s petition for review of the Board of Immigration Appeals’ (BIA) denial of his motion for reconsideration regarding the dismissal of his appeal from an Immigration Judge’s determination that he failed to establish a good-faith marriage. The court applied an abuse of discretion standard to the BIA’s denial of the motion, reviewing de novo any associated questions of law or due process claims. Regarding Mendoza’s argument that the agency improperly treated evidence, the court found no abuse of discretion because the BIA addressed his assertions with specific citations and did not act arbitrarily, irrationally, or contrary to law. On Mendoza’s due process challenge, the court held that the BIA correctly declined to consider the claim as it was raised for the first time in a motion for reconsideration rather than on appeal, and further determined there was no error in concluding the claim failed on the merits because the record did not demonstrate Immigration Judge bias or fundamental unfairness. As a practical consequence, the petition is denied, leaving the BIA’s order dismissing Mendoza’s appeal and his underlying immigration status unchanged.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-06-30

The Ninth Circuit denied the petition for review filed by Maria Elena Escalante-Escobar and her minor child regarding the Board of Immigration Appeals’ decision affirming the Immigration Judge’s denial of asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The court applied the substantial evidence standard of review to all three claims, a deferential standard permitting reversal only when any reasonable adjudicator would be compelled to conclude otherwise. Regarding asylum and withholding of removal, the court held that the agency’s finding was supported by substantial evidence because the Petitioner failed to establish a necessary nexus between the alleged harm and a protected ground. The record indicated the assault was a random act of violence rather than motivated by race, religion, nationality, membership in a particular social group, or political opinion; consequently, the court declined to address the legal cognizability of the proposed “criminal victims that fought back” social group as it was unnecessary to the holding. For CAT relief, the court affirmed that the Petitioner failed to demonstrate it was more likely than not she would be tortured upon removal, noting that generalized fear of violence and a lack of evidence regarding government acquiescence were insufficient to meet the statutory standard. As a practical consequence, the petition is denied, the temporary administrative stay of removal is lifted, and the motion for a stay of removal is denied, allowing for the enforcement of the removal order.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-06-30

The Ninth Circuit denied Luis Alonso Perez’s petition for review of the Board of Immigration Appeals’ order dismissing his appeal from an immigration judge’s decision denying his applications for asylum, withholding of removal, and relief under the Convention Against Torture (CAT). The court held that Perez failed to establish clear error in the agency’s adverse credibility determination, which was supported by substantial evidence. Specifically, the court found that Perez’s testimony contained specific and cogent inconsistencies regarding the source of the threats he feared—leaving the immigration judge uncertain whether the mayor, a street vendor association president, or gang members were responsible—and discrepancies concerning his employment status prior to leaving El Salvador. Although the court noted the immigration judge arguably failed to provide an opportunity to clarify the employment history inconsistency, it ruled that the totality of the circumstances still compelled the conclusion that the credibility finding was not clearly erroneous. Consequently, in the absence of credible testimony, Perez’s claims for asylum and withholding of removal failed. Additionally, the court deemed Perez’s arguments regarding CAT protection and due process violations abandoned because his brief did not meaningfully challenge those determinations. The petition is denied, leaving the BIA’s order affirming the denial of relief in effect.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-06-30

The Fourth Circuit affirmed the district court’s order dismissing Willie Darnell Deramus’s pro se civil rights complaint under 42 U.S.C. § 1983 for failure to state a claim pursuant to 28 U.S.C. § 1915A(b)(1). The court reviewed the record and determined that no reversible error occurred in the district court’s application of the legal standard, concluding that the complaint did not sufficiently allege facts supporting a valid constitutional violation. As a result of this affirmation, the dismissal of the lawsuit stands, and Deramus receives no relief on his claims against the New Hanover County Sheriff’s Office and Wellpath.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-06-30

The Fourth Circuit affirmed the district court’s dismissal of Jeremy Fontanez’s 28 U.S.C. § 2241 petition, holding that he failed to exhaust his administrative remedies prior to filing and did not establish that exhaustion should be excused under the circumstances of this case. The court applied the statutory exhaustion requirement governing habeas corpus petitions by federal prisoners, finding no error in the district court’s determination that Fontanez had not satisfied this prerequisite. As a result, the dismissal of the petition stands, and Fontanez is barred from pursuing relief through this avenue until proper administrative procedures are completed or an exception to exhaustion is successfully demonstrated.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Tenth Circuit

Filed: 2026-06-30

Docket: 5:25-CV-01349-PRW)

The Tenth Circuit reversed the district court’s denial of a habeas corpus petition filed by Rigoberto Santillan Quiroz, an unadmitted noncitizen detained in the interior of the United States pending removal proceedings. The court held that 8 U.S.C. § 1225(b)(2)(A), which mandates detention for “applicants for admission” who are not clearly entitled to be admitted, applies only to noncitizens at the border or ports of entry and does not extend to those arrested within the country’s interior. Consequently, Quiroz is subject to the authority of 8 U.S.C. § 1226(a), which permits immigration officials to release a noncitizen on bond pending removal proceedings. The court applied de novo review to interpret the statutory text and context of the Immigration and Nationality Act. The opinion established that while “applicant for admission” is a defined term encompassing unadmitted persons present in the interior, the phrase “seeking admission” requires an ongoing action to request lawful entry from abroad. Because Quiroz had already entered the country without inspection, he could not be “seeking admission,” thereby excluding him from the mandatory detention scheme of § 1225(b)(2)(A). The court rejected the Government’s argument that the statutory definition of “applicant for admission” implicitly deems all such persons to be “seeking admission,” noting that such an interpretation would render the phrase “seeking admission” superfluous and contradict the statute’s border-focused structure. Furthermore, the court found that interpreting § 1225(b)(2)(A) to cover interior arrests would create surplusage in § 1226(c), which provides exceptions to bond eligibility for inadmissible aliens under § 1226(a). The decision was also supported by the canon of constitutional avoidance, as the Government’s interpretation would raise serious Due Process concerns regarding the indefinite detention of millions of noncitizens without individualized bond hearings. On remand, the district court is ordered to grant Quiroz’s petition and direct the Government to either provide him with a bond hearing or release him within seven days.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-06-30

The Fourth Circuit denied Jamell Tremaine Robinson a certificate of appealability and dismissed his appeal from the district court’s order denying relief on his 28 U.S.C. § 2255 motion. The court held that an appeal in such cases is not permissible unless a circuit justice or judge issues a certificate of appealability, which requires a substantial showing of the denial of a constitutional right. Under the standard applied, because the district court denied relief on the merits, Robinson was required to demonstrate that reasonable jurists could find the district court’s assessment of his constitutional claims debatable or wrong. After independently reviewing the record, the court concluded that Robinson failed to make this requisite showing. Consequently, the appeal is dismissed without oral argument.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-06-30

The Fourth Circuit affirmed the district court’s order denying relief on Ronesha Greene-McNeil’s 28 U.S.C. § 2241 petition challenging the execution of her sentence. The court held that the petitioner failed to exhaust her administrative remedies regarding the claims raised and failed to demonstrate that exhaustion would have been futile. Applying a standard of review that found no reversible error in the district court’s factual findings and legal conclusions, the appellate court affirmed the denial of habeas relief without oral argument.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.